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Five years after the Marine and Coastal Act became law and made provision for Marine Conservation Zones, a new kind of marine protected area, the Welsh Government has finally enacted the relevant sections of the Act and Skomer Marine Nature Reserve has automatically been reclassified as an MCZ.

Although there was great hope that MCZs would greatly improve the number of marine protected areas and the protection of marine wildlife, there will be no change to the management of Skomer MNR despite what some media reports have said. Also, despite reports in the press and TV coverage, Skomer Island is not part of the new MCZ. It is surrounded by the MCZ but certainly not in it.

Perhaps the most positive thing to be taken from the Ministerial announcement is that Welsh Government has promised that there will be no loss of protection. While this might not seem much to cheer about, it could have been much worse. Management of MNRs was the responsibility of the statutory nature conservation body – the Countryside Council for Wales for Skomer MNR until CCW was dissolved in 2013 and its duties taken on by Natural Resources Wales. On the other hand, management responsibility for MCZs is government’s, together with any other authority with duties in the marine environment. Thankfully NRW has been told that Welsh Government expects it to continue to manage Skomer MCZ.

There remain threats to Skomer MCZ’s management into the future though. At least the same level of resources are needed to maintain the specialist team and the facilities they need for management and to continue the most comprehensive suite of marine wildlife monitoring in one place in Britain. But NRW’s budget is being slashed by government and in turn NRW is making huge cuts across its full range of duties. How much of a priority will the imposed burden of funding MCZ management be?

In the slightly longer term, changes to Wales’ approach to managing European Marine Sites, including Pembrokeshire Marine Special Area of Conservation that Skomer MCZ lies within, are a risk to maintaining the effective long term protection of Skomer MCZ, far less even thinking about improving that protection.

So the message is this: the change from MNR to MCZ is essentially cosmetic. It doesn’t mean that those of us who care about effective marine conservation and the MNR can relax and think the job’s done. It certaibly is not. We need to keep the pressure on NRW and Welsh Government to make sure they stick to their promises not to let the protection slip and to continue to press for greater protection and the prohibition of all activity that removes or damages wildlife and the other natural features in the MCZ.

“My students and I have probed Department for Environment, Food and Rural Affairs, the Marine Management Organisation and various inshore fisheries and conservation authorities and it seems that virtually no new protection is on offer. In fact they seem to be falling over themselves to reassure the fishing industry that the zones will be open to business as usual”

“I think this leaves us in a worse position than before the Marine Act was conjured into being. Before there was nothing and we knew it. Now there is the illusion of protection. The person in the street will think the sea is well looked after at last, but there is still nothing. This network is worse than useless.”

Asks an article in the spring edition of The Marine Biologist, published by the Marine Biological Association of the UK. The article recounts the history of the Skomer MNR and explores the future of marine conservation in Wales following the catastrophic MCZ consultation: it doesn’t paint an optimistic picture. Download a the article here.

“The devastation of a fishery shows the idiocy of much environmental politics” says an article in The Economist, a magazine usually more given to business and profits rather than environmental concern. There’s a few minor glitches in it but it’s obvious that even their columnist can see how badly politicians have failed and continue to fail the marine environment. Read it here.

“The struggle to win the attention of the public and the will of politicians to the cause of the conservation of nature at sea has not been easy. Blaise Bullimore describes the slow progress that has been made, the part that Skomer Marine Nature Reserve has played, and the uncertain prospects for effective marine conservation management.”

Read the article published in the summer 2013 edition of Natur Cymruhere (2Mb pdf).

could you please tell me why you think people are making misleading and incorrect implications and claims about the impacts of Wales’ possible highly protected Marine Conservation Zones on recreational and other activities that are benign and will require little or no management. when all that is being said is directly out of the consultation document and indeed the proposed wording which is found on pages 88,89 and 90 of that document as i see it you are just giving a very biased view of HPMCZs it has been a flawed consultation from the start backed up by flawed and very questionable science and i am interested to know why you feel they are even needed as a high level of protection already exists in a large percentage of welsh coastal waters i am sure you will not respond but i can live in hope and may even change my stance if you can prove undeniably that HPMCZs will be of benefit

As it raises several important issues we thought we would post our reply on the website.

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Dear A

Since you were not expecting a reply I hope this doesn’t come as too much of a surprise.

You ask several questions and make several statements that I will try and respond to one at a time, though not in the same order as it makes sense to explain some things before others.

1) “Flawed consultation”. We wholeheartedly agree that the consultation has been flawed. Actually, we’d be inclined to be much less diplomatic. What’s more, all the non-governmental conservation organisations that have been lobbying for HPMCZs for many years agree too.

The consultation document is indeed very poor – easily misunderstood and ambiguous. It needs a huge amount of effort to dig down to the relevant details and also needs familiarity with other documents (such as the Site Selection Guidance) to even begin to understand parts of it.

The engagement process by the Welsh Government has been equally as bad, possibly worse. Liaison with local communities and all interests other than fisheries (who had been promised one-to-one meetings by Welsh Government for months before the consultation) was too slow and too late. In many cases answers and clarifications have been even less clear than the document.

2) “Flawed and very questionable science”. We do not agree that HPMCZ science is flawed and very questionable. What do you base this assertion on? What HPMCZ science have you read that is flawed and questionable?

There is huge body of careful research published from studies in MPAs across the world. The PISCO report linked from the MPA Science page of the WWMC website summarises some of this in an accessible and readable way. The CCW report on evidence of benefits and opportunities from HPMRs goes into more detail, particularly from a British Isles context – it also downloadable from the website. There is considerably more robust MPA science out there and it is being added to all the time.

However, there is no guarantee that science or evidence will be used responsibly. It may be used without really understanding it or without good awareness of all the relevant science available. It certainly appears that Welsh Government have done so in this case, though that still doesn’t undermine the case for HPMCZs.

But all too often, when someone wants to attack science they cherry-pick bits and pieces in isolation or out of context to try and undermine it or to support a particular ideological position. Attempting to cast doubt on scientific evidence by claiming lack of 100% certainty (see below) or that it is flawed is a well known technique to avoid having to provide evidence to support a contrary position.

3) “a high level of protection already exists in a large percentage of welsh coastal waters” By this we assume you are referring to marine Special Areas of Conservation. Whilst 36% or so of Welsh territorial sea area is indeed designated as marine SAC, designation does not equal protection.

In fact, the SACs have resulted in extremely little additional protection for Welsh seas and at the last assessment well over half of the designated conservation features were judged to be unfavourable. The only really significant additional protection across all Welsh marine SACs was the introduction of a ban on scallop dredging a couple of years ago – and that was certainly largely a result of two complaints to the European Commission about the damage being caused and lack of protective management.

So no, there certainly isn’t a high level of protection in a large percentage of Welsh coastal waters.

4) “why you think people are making misleading and incorrect implications and claims” There are two ways of interpreting this question: what is the evidence for WWMC to make this claim; or what are people’s reasons for making misleading statements. One at a time –

The evidence is that we have heard at meetings and one-to-one conversations and read online and in the press many people making claims that everything from diving to dog-walking, sailing to building sandcastles will be banned in HPMCZs. Most of the time they cannot explain where they got these ideas from – simply that they think it might happen. Some will accept clarification when it is offered – either by reference to the relevant parts of the document or by Welsh Government officials or by marine staff from the Countryside Council for Wales, WG’s nature conservation advisors. But some simply people simply keep repeating these things will be banned despite being corrected and reassured that they are wrong – why is that?

The reasons – we cannot say for sure, but perhaps either some people simply do not believe what they are told, or it could be that some are deliberately using scare-tactics to generate opposition. If you are one of those whose activity would be banned from HPMCZs under the proposals, for example commercial fishermen, doesn’t repeating that diving and other recreational activities will also be banned make good sense to scare people into joining your side in opposition?

5) “all that is being said is directly out of the consultation document” What is being said is not actually directly out of the document. It is an interpretation based on misunderstanding one part of the document out of context and disregarding all the other parts that give a clearer picture. In particular, Table C in Annex 4 gives a far clearer explanation of what may (and the document stresses may) need to be managed in some way and under what circumstances – and that management most assuredly does not automatically equal prohibition. Certainly the information in the document could have been far clearer but it would have needed to be site specific and that detail is promised for future rounds of consultation.

“giving a very biased view of HPMCZs” WWMC has done its best to provide an evidence based view of both the need for and the benefits of HPMCZs. Our view is certainly based on acceptance of the need for healthy ecosystems and biodiversity and understanding that these are necessary and vital part of the planet’s life support systems for humans as well as every other living thing. If that is bias, then we’re guilty.

6) “prove undeniably that HPMCZs will be of benefit” Two problems with this. Firstly, it is impossible to actually prove anything before it happens – all that can be done is base expectations on previous experience. Secondly, science doesn’t work that way. It is a common misunderstanding that it should “prove” things or provide 100% certainty – it doesn’t. Science is about collecting evidence, testing hypotheses and determining the probability that something is the case.

Scientific assessments of the effects of Marine Protected Areas are based on these principles. They collect the best evidence possible. The sea is a very dynamic and changeable place so it should be no surprise that the detailed effects of MPAs differ from place to place, but the important thing is that the same general patterns emerge time after time. So, can we say specific changes will happen at a specific time? No. But we can predict the kinds of changes that are likely or probable to happen. Exactly this happened in the Skomer MNR when scallop dredging and collection was prohibited in 1989. It was predicted that the population might recover. It took ten years before it got going, but since then it has taken off and volunteer divers are again helping MNR staff resurvey the population this year.

So yes, the consultation is bad, but the need and case for HPMCZs is rock solid.

We don’t expect to change your mind though we have tried and will be delighted if you do.

Because you raised several important issues we will be posting this on the website for the benefit of others.

The Welsh Government’s highly protected MCZ project is in trouble: your support is needed urgently.

Triggered in part by a truly poor consultation document and a badly mishandled consultation process, well organised and determined opposition to the to HP MCZ proposal has developed.

The badly handled consultation has generated legitimate concerns, but misleading and alarming disinformation spread by a combination of fishing interests and people who seem ideologically opposed to HP MCZs has frightened many people blindly objecting to the proposals.

The opposition is so well orchestrated that there appears to be real risk the entire process will be abandoned by Welsh Government unless they receive a sufficiently large number of responses supporting HP MCZs.

It is important that Welsh Government stick to their policy both for the sake of the Welsh marine environment and for the Skomer MNR in particular.

You will need to fill in some information and delete any text not relevant to you. And please customise it as much as you can – the fewer identical responses Welsh Government receive the better – and don’t forget to save it with a suitable filename that identifies it as yours before you e-mail it!

Most importantly, please tell all your friends and colleagues that care about protecting the marine environment that their support is needed too. Please, please tweet, Facebook, blog or e-mail a link to this page to spread the word. Consultation responses must be received by 31 July so you don’t have long.

The WG representative gave the key assurances that there is no intention of prohibiting look-but-don’t-take recreational diving in highly protected MCZs.

The diving representatives assured WG that the diving community as a whole are supportive of MCZs. However, they were concerned that the WG had a negative attitude toward diving and stressed the high training and environmental standards and responsibility of the overwhelming majority of divers.